- 7 - June 16, 1982) in the amount of $807.38. Respondent did not credit petitioners’ 1979 account with interest for the period June 16 through June 28, 1982. On June 13, 1983, when respondent refunded to petitioners the overpayment petitioners claimed on their 1982 tax return, respondent did not credit petitioners’ 1982 account with interest for the period June 1 through June 13, 1983. B. The Tax Court Proceeding and Surrounding Circumstances On October 15, 1986, respondent sent to petitioners a notice of deficiency, in which respondent made adjustments on account of TEA items and determined deficiencies and additions to tax as shown in table 1. Table 1 Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(a)(1) 6653(a)(2) 6659 1978 $14,607 $730 –- $4,382 1979 8,208 410 -- 2,462 1981 9,537 477 1 2,861 1982 8,129 406 2 2,439 1 50 percent of the interest due on $9,537. 2 50 percent of the interest due on $8,129. Respondent also determined that petitioners’ deficiencies are subject to an increased rate of interest under sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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